CMS Issues CY 2020 Home Health PPS Rate Update

On July 11^th, the Centers for Medicare and Medicaid Services (CMS) released the Calendar Year (CY) 2020 Home Health Prospective Payment System (PPS) Rate Update, including changes to the Home Health Value-Based Purchasing Model, Home Health Quality Reporting Requirements, and Home Infusion Therapy Requirements.

LeadingAge NY, along with our national organization, will be doing an analysis of this update. We encourage you to offer us your feedback on the proposed rule.

The proposed payment update is 1.3 percent, or $250 million, in aggregate. The update calls for a 1.5 percent payment increase; however, this number is offset by a 0.2 percent decrease ($40 million) in aggregate payments due to reductions per the new rural add-on policy mandated by the Bipartisan Budget Act of 2018. The rate updates also include adjustments for anticipated changes with implementation of the Patient-Driven Groupings Model (PDGM) and a change to a 30-day unit of payment, the use of updated wage index data for the home health wage index, and updates to the fixed-dollar loss ratio to determine outlier payments. LeadingAge NY continues to be concerned with payment decreases based on behavioral assumptions built into the PDGM payment structure. CMS’s update increases this cut from 6.42 percent in last year’s rate update to over 8 percent in this proposal.

This proposal also phases out and then eliminates prepayment for home health services. CMS proposes to reduce the Request for Anticipated Payment (RAP) split-percentage payment to 20 percent (currently at 60 percent for an initial episode and 50 percent for subsequent episodes) for existing home health agencies (HHAs) beginning in CY 2020, with elimination of split-percentage payments for all HHAs in CY 2021.

Other changes include:

Proposal to modify the payment regulations pertaining to the content of the home health plan of care;
Proposal to allow therapist assistants to furnish maintenance therapy;
Proposed payment rate changes for home infusion therapy temporary transitional payments for CY 2020;
Payment proposals for new home infusion therapy benefit for CY 2021;
Regulatory burden reduction – Patients over paperwork and enhance and modernize program integrity;
Paraprofessional roles – Improving access to care;
Home Health Quality Reporting Program – Support MyHealthEData Initiative; and
Home Health Value-Based Purchasing Model – Making performance data public.

For more information, please see the following:

We will issue a more detailed summary of the proposal soon. Please contact LeadingAge NY with your thoughts, questions, and concerns so we can provide substantive comments by the Sept. 9^th deadline.

Contact: Meg Everett, meverett@leadingageny.org, 518-867-8871